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National Center on Tribal Early Childhood Development

CCDF Final Rule: Implementation Training for American

Indian and Alaska Native Grantees

National Center on Tribal Early Childhood Development 1

Welcome


“Let us put our minds together and see what life we can make for our children.”—Sitting Bull

Introductions


Agenda


Training Goals To provide training and technical assistance (T&TA) to

American Indian and Alaska Native (AI/AN) Lead Agencies to guide them in implementing the CCDF final rule.

To help AI/AN Lead Agencies identify areas that need to be refined or improved, per the CCDF final rule, so that services and activities continue to be responsive and appropriate for the needs of AI/AN children and families.

To provide AI/AN Lead Agencies an opportunity to gauge their CCDF final rule readiness level, according to their current work and services provided, and then define goals and action steps to meet the CCDF final rule requirements by the end of the current CCDF tribal plan cycle.


Training Objectives AI/AN CCDF Administrators will actively participate in

presentations, discussion groups, and peer-to-peer exchanges for developing action plans regarding the implementation of the CCDF final rule.

AI/AN CCDF Administrators and staff will have opportunities to share plans, ideas, and strategies to meet CCDF requirements.

AI/AN CCDF Administrators and staff will discuss concrete ideas for ways to implement the CCDF requirements; strategies will be tailored to reflect challenges and opportunities within administrators’ Tribes and in working with States.



Background: CCDF Final Rule


Background

Child Care and Development Block Grant

(CCDBG) Act of 2014

Notice of Proposed

RulemakingCCDF Final Rule


Source: Child Care and Development Fund (CCDF) Program, 81 Fed. Reg. 67,438, 67, 444 (Sept. 30, 2016) (codified at 45 C.F.R. pt. 98).

Major Provisions of the CCDF Final Rule

1. Protect the health and safety

of children in child care

2. Help parents make informed

consumer choices

3. Enhance the quality of child

care

4. Provide equal access to stable

child care for low-income families


Source: Child Care and Development Fund (CCDF) Program, 81 Fed. Reg. 67,438, 67,438- 41 (Sept. 30, 2016) (codified at 45 C.F.R. pt. 98).

CCDF Final Rule for AI/AN CCDF Grantees Clarifies which provisions of the law apply to

AI/AN CCDF grantees. Establishes three categories of AI/AN grantee

CCDF allocations. Creates tiered requirements to provide greater

flexibility to grantees with lower levels of funding.


Source: Child Care and Development Fund (CCDF) Program, 81 Fed. Reg. 67,438, 67, 441 (Sept. 30, 2016) (codified at 45 C.F.R. pt. 98).

Tiered Approach to AI/AN CCDF Grantee Requirements Requirements for AI/AN CCDF grantees are

based on allocation size.


Small Allocation

Less than $250,000

Medium Allocation

$250,000 to $1 million

Large Allocation

More than $1 million

Source: Child Care and Development Fund, 45 C.F.R. § 98.80 (2016).


Tiered Requirements at a Glance

Large Allocation

• Subject to themajority of CCDFrequirements

• Allowed some AI/ANgrantee exemptions



Exemptions for All AI/AN CCDF Grantees Consumer education website Market rate survey or

alternative methodology Increased access to high-

quality care in concentrations of poverty

Early learning and developmental guidelines

Licensing requirements applicable to child care services

Certification to develop the CCDF Plan in consultation with the state advisory council

Matching funds requirements Identification of public or

private entities designated to receive private funds

Five percent administrative cap

A definition of very low income A description of how the Lead

Agency will meet the needs of certain families

Training and professional development framework

Quality progress report (QPR)




Small Allocation

Large Allocation

• Subject to themajority of CCDFrequirements

• Allowed some AI/ANgrantee exemptions

Medium Allocation• Subject to the

majority of CCDFrequirements

• Allowed the sameexemptions as largeallocation grantees

• Also exempt fromthe requirement tooperate a certificateprogram




Large Allocation

• Subject to the majority of CCDF requirements

• Allowed some AI/AN grantee exemptions


majority of CCDF requirements

• Allowed the same exemptions as large allocation grantees

• Also exempt from the requirement to operate a certificate program

Small Allocation• Exempt from the

majority of CCDF requirements, but subject to some requirements

• Must spend funds in alignment with CCDF purposes and goals

• Must submit an abbreviated CCDF Plan


Requirements for Small Allocation Grantees


Health and safety Monitoring (with flexibility to propose an alternate approach) Background checks (with flexibility to propose an alternate

approach) Quality spending (except infant/toddler quality spending

requirements) Eligibility definitions of Indian child and Indian

reservation/service area Fifteen percent administrative cap Fiscal, audit, and reporting Any other requirement defined by the Secretary of Health and

Human ServicesSource: Child Care and Development Fund, 45 C.F.R. § 98.83 (2016).



Large Allocation

• Subject to the majority of CCDF requirements

• Allowed some AI/AN grantee exemptions


majority of CCDF requirements

• Allowed the same exemptions as large allocation grantees

• Also exempt from the requirement to operate a certificate program

Small Allocation• Exempt from the

majority of CCDF requirements, but subject to some requirements

• Must spend funds in alignment with CCDF purposes and goals

• Must submit an abbreviated CCDF Plan


Compliance Date for AI/AN CCDF Grantees


Compliance is determined through review and approval of Fiscal Year 2020–2022 tribal CCDF Plans that become effective on October 1, 2019.

Source: Child Care and Development Fund (CCDF) Program, 81 Fed. Reg. 67,438 (Sept. 30, 2016) (codified at 45 C.F.R. pt. 98).

Pathway to CCDF Final Rule Implementation


Where are you now? Building an understanding

of applicable final rule requirements

Assessing readiness to meet the requirements

Working to align with the requirements and preparing for 2019, when new plans are due


Laying the foundation: Beginner stage of meeting

CCDF requirements

Advanced stageof meeting

CCDF requirements

Intermediate stage of meeting

CCDF requirements

High quality

Successful Implementation of the CCDF Final Rule for Your Program, Community, and Tribe


Major Provisions of the CCDF Final Rule


1. Protect the Health and Safety of Children in Child Care


Health and Safety Overview Applies to all AI/AN CCDF grantees,

regardless of allocation size and regardless of whether they offer direct services.

Includes health and safety standards (such as those for immunizations), training, monitoring, and criminal background checks.

Exempts AI/AN grantees from the requirement to have licensing applicable to child care services.

Allows AI/AN grantees to exempt relative care providers from the healthand safety requirements.


Requirements for All AI/AN CCDF Grantees Health and safety standards for required topics that are

subject to monitoring Age-appropriate immunizations Standards that address group size limits, the ratio

between the number of children and the number of caregivers, and required qualifications for caregivers in child care settings

Preservice/orientation training and ongoing training on the required topics

Monitoring of CCDF providers, with flexibility to propose an alternative monitoring strategy

Comprehensive criminal background checks for all CCDF providers, with flexibility to propose an alternative approach


Source: Child Care and Development Fund, 45 C.F.R. § 98.41, § 98.83 (2016).

Required Health and Safety Topics


1. Prevention and control of infectious diseases (including immunizations)2. Prevention of sudden infant death syndrome and use of safe sleeping practices3. Administration of medication, consistent with standards for parental consent4. Prevention and response to emergencies due to food and allergic reactions5. Building and physical premises safety

6. Prevention of shaken baby syndrome, abusive head trauma, and child maltreatment7. Emergency preparedness and response 8. Handling and storage of hazardous materials and the appropriate disposal of biocontaminants9. Appropriate precautions in transporting children, if applicable10. Pediatric first aid and cardiopulmonary resuscitation 11. Recognition and reporting of child abuse and neglect


Reflections on Health and Safety Requirements

Technical assistance needsPolicy questions or clarifications Implementation strategies and examplesAdditional questions?


2. Help Parents Make Informed Consumer Choices


Consumer Education Overview

Applies to AI/AN grantees with medium and large allocations.

Includes: provider-specific information; additional consumer education

information for parents, providers, and the public;

consumer statement; and parental compliant hotline.

All AI/AN grantees are exemptfrom the requirement to build a consumer education website.


Requirements for Medium and Large Allocation AI/AN Grantees Collect and disseminate information regarding:

tribal policies and procedures; provider-specific information; aggregate annual data on death, serious injuries, and instances of child

abuse; referrals to local child care resource and referral organizations; how parents can contact the AI/AN Lead Agency or its designee and

other programs to help them understand consumer education information;

availability of child care and related services; research and best practices; policies regarding social-emotional behavioral health; and developmental screening.

Develop and share a consumer education statement for CCDF families.



Parental Complaints

AI/AN CCDF grantees with medium and large allocations are required to establish or designate a hotline or similar reporting process that allows parents to submit complaints about child care providers.



Reflections on Consumer Education Requirements



3. Enhance the Quality of Child Care


Quality Improvement Overview Requirements for all AI/AN grantees: an increasing quality set-aside; reporting on quality expenditures each fiscal year; and Pre-service or orientation training and ongoing professional

development on health and safety standards and child development.

AI/AN grantees with medium and large allocations are also subject to requirements for an infant/toddler set-aside, starting in FY 2019, and a description of strategies to increase the supply and

improve the quality of child care services for certain children.

AI/AN grantees are exempt from the requirement to submit the QPR.


Quality Spending Requirements



Quality Spending FFY 2017 FFY 2018 FFY 2019 FFY 2020 FFY 2021 FFY 2022(and ongoing)

% Quality Set-Aside (All) 4% 7% 7% 8% 8% 9%

% Infant-Toddler Set-Aside (Medium and Large) 0% 0% 3% 3% 3% 3%

Total % Quality (Small) 4% 7% 7% 8% 8% 9%

Total % Quality (Medium and Large) 4% 7% 10% 11% 11% 12%

Allowable Quality Improvement ActivitiesQuality funds must be used to carry out at least one of the following:


Training and professional development

Early learning and developmentguidelines

Tiered quality rating and improvement system

Quality and supply of infant/toddler services

Child care resource and referral services

Licensing and health and safety requirements

Quality evaluation

Accreditation

High-quality program standards

Other measurable quality activities as determined by the AI/AN Lead Agency


Training and Professional Development All AI/AN grantees must describe in the CCDF plan their

established requirements for the following: Accessible preservice or orientation training in health and

safety standards and child development Ongoing, accessible professional development, including the

minimum hours required annually, that • maintains and updates health and safety training standards;• incorporates social-emotional behavior intervention models for

children; and • to the extent practicable, is appropriate for different age groups,

English learners, and children with developmental delays and disabilities.

All AI/AN grantees are exempt from the requirement to have a professional development framework.


Source: Child Care and Development Fund, 45 C.F.R. § 98.44, § 98.83 (2016).

Building the Supply of High-Quality Care AI/AN grantees with medium and

large allocations must provide a description of their strategies to increase the supply and improve the quality of child care services for: children in underserved areas; infants and toddlers; children with disabilities; and children who receive care during

nontraditional hours.



Reflections on Quality Requirements



4. Provide Equal Access to Stable Child Care for Low-Income Families


Eligibility Overview

Requirements for all AI/AN grantees Eligibility definitions of “Indian child” and service

area Dual eligibility for AI/AN children

Requirements for grantees with medium and large allocations Additional eligibility criteria Stable financial assistance Parental choice Payment rates Payment practices


Eligibility Requirements for Small Allocation Grantees Eligibility criteria: Define “Indian child”; and Define the service area.

Small allocation grantees have flexibility to set their own eligibility requirements


Source: Child Care and Development Fund, 45 C.F.R § 98.83 (2016).

Eligibility Requirements for Medium and Large Allocation Grantees Eligibility criteria: Younger than 13 years old; Considered an “Indian child”; Resides within the service area; Family income less than 85 percent of the grantee

median income for families of the same size; and Parent(s) working, enrolled in job training or education, or

receiving or need to receive protective services. Categorical eligibility: Option to consider any Indian child

eligible if the Tribe’s medium income is below 85% of the State Median Income, provided that services still go to those with highest need.


Source: Child Care and Development Fund, 45 C.F.R § 98.20, § 98.21, § 98.81 (2016).

Eligibility Requirements for Medium and Large Allocation Grantees (continued)

Stable financial assistance Promote continuity of care via 12-month eligibility. Support continuity during eligibility periods. Provide a graduated phase out. Ensure family co-payments do not increase within the

12-month eligibility period (with the exception of graduated phase out).

Improve access for vulnerable children and families.


Source: Child Care and Development Fund, 45 C.F.R § 98.20, § 98.21 (2016).

Parental Choice Requirements Large allocation grantees: Must

provide the parent(s) of each CCDF eligible child who receives assistance with the choice to either enroll the child with an eligible child care provider that has a grant or contract for such services, OR to receive a child care certificate.

Medium and small allocation grantees: Exempt from the requirement to provide a certificate as an option for parents.


Source: Child Care and Development Fund, 45 C.F.R § 98.30 § 98.83 (2016).

Equal Access Requirements for Medium and Large Allocation Grantees Provision of direct child care

services

Setting payment rates for child care services

Payment practices and timeliness of payments to providers

Supply-building strategies to meet the needs of certain populations

45

Source: Child Care and Development Fund, 45 C.F.R § 98.45 (2016).


Reflections on Equal Access Requirements



5. Additional CCDF Final Rule Requirements


CCDF Plan

The CCDF Plan is now effective for 3 years. Small allocation grantees will submit an

abbreviated plan. Child count declaration submitted with CCDF Plan

every 3 years (no longer annually).


Source: Office of Child Care, Administration for Children and Families, U.S. Department of Health and Human Services. (2016). FY 2017-2019 tribal plan preprint (Program instruction: CCDF-ACF-PI-2016-03). Retrieved from https://www.acf.hhs.gov/occ/resource/ccdf-acf-pi-2016-03

Coordination Requirements


Coordination between state and tribal organizations

AI/AN grantees “shall coordinate the development of the Plan and the provision of services, to the extent practicable,” and “To the maximum extent feasible, with the Lead

Agency in the State or States in which the applicant will carry out the CCDF program; and

With other Federal, State, local, and tribal child care and childhood development programs.”


Financial Requirements Fifteen percent administrative cap. Restricted use of funds: CCDF funds may not be used for school tuition for

children in grades 1 through 12; CCDF funds paid to providers through grants or

contracts may not be used for any sectarian purposes; and

CCDF funds may not be used as part of the nonfederal share or match for any other federal grant programs.

AI/AN grantees may use CCDF funds for construction or major renovation upon requesting and receiving approval from the Secretary of Health and Human Services.


Source: Child Care and Development Fund, 45 C.F.R. §98.56 § 98.83 § 98.84 (2016).

Obligation and liquidation provisions apply to tribal discretionary and tribal mandatory funds.

Tribal discretionary funds are subject to reallotment. Any expenditures not made in accordance with the

CCDBG Act, the implementing regulations, or the approved CCDF Plan will be subject to disallowance.

AI/AN Lead Agencies shall expend and account for CCDF funds in accordance with their own laws and procedures for expending and accounting for their own funds.

AI/AN Lead Agencies must describe in their CCDF plan the internal controls that are in place to ensure integrity and accountability


Financial Requirements (continued)

Source: Child Care and Development Fund, 45 C.F.R. § 98.60, § 98.64, § 98.66, § 98.67 § 98.68 (2016).

Fiscal, Audit, and Data Reporting Requirements Audits: Each Lead Agency shall have an

audit conducted after the close of each program period.

Financial reporting (696-T): Tribal Lead Agencies shall submit financial reports annually.

Data reporting (ACF-700): AI/AN Lead Agencies that receive assistance under CCDF shall prepare and submit to the secretary an annual aggregate report.


Source: Child Care and Development Fund, 45 C.F.R. § 98.65 § 98.70 (2016).

Check-Out Activity



National Center on Tribal Early Childhood Development, A Service of the Office of Child Care

9300 Lee HighwayFairfax, VA 22031

Phone: 877-296-2401

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